Patient and Public Involvement Forum for the East Lancashire Hospitals NHS Trust comments

1. The Code of Practice on Consultation (as issued by the Cabinet Office).

This states, "Although the code does not have legal force It should otherwise generally be regarded as binding on UK departments and their agencies"

Criterion 1.

Point 1.2 states, "It is important to identify proactively relevant interested parties and those whom the policy will be likely to affect. These groups should be contacted and engaged in discussion as early as possible in the policy development process." This should have been done through the groups set up for the four care streams. These four care streams were: - 1. Unscheduled/Emergency.

2. Elective/Planned Care.

3. Women's Children's and Diagnostics.

4. Long Term Conditions. However, point 1.3 goes on to say that, "Informed consultation with those stakeholders should be conducted prior to the written consultation period. Not only does this lead to a more informed consultation exercise it also ensures that the stakeholders are engaged early and have a better understanding of the policy."

This was not done in any meaningful way. Information gathering took place early on but there was never any consultation or discussion of the pre-consultation proposals. Nor was there any discussion or consultation of the options before they were issued in the public consultation document.

Point 1.8 states, "Some stakeholders.may be particularly hard to reach. It is important to engage proactively with individuals, organisations and trade associations." The only attempt to do this is through the tour bus and this will only offering information and will not be the proactive type of approach envisaged in the March 2006 report from the University of Salford. In that report it is said that, there is no evidence that this consultation has either taken place or that it is planned. An open invitation to provide a speaker is not sufficient.

Criterion 2.

Point 2.3 states, "As far as possible, consultation should be completely open, The risks and consequences of doing nothing should be outlined." This requirement has clearly not been complied with as options such as, "Do minimum" and "New build", were ruled out before the written consultation started.

2. Pre-Consultation.

i. Although representatives of outside bodies had some involvement in the work of the care streams', that involvement was limited. There was a concentration on providing information rather than on the building up of service models and then the critical examination of those service models.

ii. The, care stream' groups were not given the opportunity to view or comment on the pre-consultation proposals before they were made public in October 2005.

iii. Care Stream public' question and answer sessions were held in February 2006 but these were not open to the general public and were purely question and answer sessions and did not properly engage the public iv. Despite early assurances that the PPIF would be involved in all stages of the review this did not happen. In particular the PPIF was not involved in any shape or form in the formulation of the options before they were made public. There were purportedly four options but three were such obvious non-starters that a mockery was made of the process. As a consequence the public was enraged and has subsequently refused to believe that they are being consulted in any meaningful way.

v. It is worthy of note to mention that a fifth option emerged that closely followed the one suggested jointly by the East Lancashire PPIF's.

vi. Strong representations had to be made by all the East Lancashire PPIF before forum representation was achieved on the key committees, the Health Economy Steering Group, the Evaluation Panel and the Joint PCT Committee. This inclusion though was at too late a stage to be really effective.

vii. The Evaluation Panel met on 03.03.06 and was informed by the Chair and Facilitator that it had to evaluate Options A and B (or 5 and 3, which confused members of the panel). Other options that several members mentioned were categorically turned down.

viii. The Patient's Reference Group did not operate in any meaningful way. The Group's role appeared to be to consider and comment on the options. During the limited debate of them there was severe criticism from a consultant in Accident and Emergency and from General Practitioners as well as from others who were present. Despite these severe criticisms little change was made to the options other than the merging of them.

3. Consultation.

i. There was a failure to ensure that the Public Consultation Summary had been issued to most households before the Public Consultation Events were held. This is a major reason why audiences have been very small and uninformed. (As late as 19.06.06 many households have still not received the document.) ii. Public Consultation Events were held at inappropriate venues and at inconvenient times resulting in a failure to ensure reasonable numbers of the public attending and a meaningful engagement of the public in the process.

iii. Real and genuine options were not put before the public with the arguments both for and against being stated. On 13.06.2006, following enquiry by a newspaper reporter, it was discovered that doctors and senior managers had produced a paper three months previously, setting out their concerns and the drawbacks of the proposals. In addition full information on numbers of patients, times of wait, length of stay, journey times etc was not made public. The question of transport times has never been fully answered, even at this late stage iv. The summary consultation document resembled a free newspaper rather than an important document requiring some action by the recipient. Many people probably discarded it without reading because of that. The response form was poorly situated on the last but one page and insufficient mention was made of it earlier in the document.

v. Publicity about the public consultation meetings was inadequate. Use should have been made of surgeries, hospitals and other places involved with health and welfare.

vi. Only two options have been put to the public and the only difference between these relates to the location of the consultant based in-patient obstetrics, gynaecology and neonatal intensive care services. This is contrary to Criterion 2.3 of the Code of Practice on Consultation written objections were made by PPIF members prior to the publication of the options.

The reason for making the above comments is best evidenced by setting out the situation at the various public events: - a. 05.05.2006 Padiham Town Hall.

Venue central and convenient.

Time 2pm, which excluded people in employment.

Result approximately 55 members of the public in attendance.

b. 08.05.06 Bacup Leisure Centre.

Venue on the outskirts of the town.

Time 6pm, clashing with evening mealtime and inconvenient for people in employment and those with family commitments.

Result 5 members of the public in attendance.

c. 09.05.06 Barnoldswick Community Centre.

Venue central and convenient.

Time 1.30pm, which excluded people in employment.

Result approximately 23 people present.

d. 10.05.06 Accrington, The Globe Centre.

Venue remote from town centre.

Time 6pm, clashing with evening mealtime and inconvenient for people in employment and those with family commitments.

Result 2 members of the public present.

e. 11.05.06 Clitheroe Town Council Chamber.

Venue in town centre.

Time 6pm, clashing with evening mealtime and inconvenient for people in employment and those with family commitments.

Result 9 members of the public present.

f. 15.05.06 Burnley Town Hall.

Venue in town centre.

Time- 6pm, clashing with evening mealtime and inconvenient for people in employment and those with family commitments.

Result 70 80 members of the public present.

g. 16.05.06 Nelson Town Hall.

Venue in town centre.

Time 6pm, clashing with evening mealtime and inconvenient for people in employment and those with family commitments.

Result 25 members of the public present.

h. 18.05.2006 Accrington and Rossendale College, Rawtenstall.

Venue adjacent to town centre.

Time 6pm, clashing with evening mealtime and inconvenient for people in employment and those with family commitments.

Result 7 members of the public present.

i. 22.05.2006 Blackburn Library.

Venue in town centre.

Time 10am, which excluded people in employment. (There was a further meeting at 6pm on 05.06.2006.) Result 6 members of the public present.

j. 23.05.2006 Haslingden Community Link.

Venue adjacent to town centre.

Time 6pm, clashing with evening mealtime and inconvenient for people in employment and those with family commitments.

Result ?

k. 24.05.2006 Municipal Hall Colne.

Venue central and convenient.

Time 10am, which excluded people in employment.

Result 30 40 members of the public present.

l. 26.05.2006 Darwen Health Centre.

Venue in town centre.

Time 1.30pm, which excluded people in employment. (There was a further meeting at 6pm on 07.06.2006.) Result m. 05.06.2006 Blackburn Library. Venue in town centre.

Time 6pm, clashing with evening mealtime and inconvenient for people in employment and those with family commitments. Result 9 members of the public present.

n. 07.06.2006 Darwen Health Centre.

Venue in town centre.

Time 6pm, clashing with evening mealtime and inconvenient for people in employment and those with family commitments.

Result 1 member of the public present A further means of public engagement that has been used is the tour bus. Despite the best efforts of those engaged in running it and their active capturing of passers by it is extremely limited in its effectiveness. At best it can do little more than raise public awareness that the CSR is taking place and perhaps answer a few questions. The concerns and drawbacks expressed by doctors and senior managers will not be mentioned. It is also possible that those engaging with the tour bus have already submitted a response. Indicative of the failure to engage the public is the fact that only a few hundred written responses have been received.

In March 2006 the University of Salford produced an evaluation report on the public engagement process within the CSR, across the East Lancashire Health Economy. Various criticisms were made in that report and requirements listed. As is stated in this document they have not all been addressed.

4. Content.

i. The two options presented provide no real choice this effectively makes the public involvement exercise meaningless rather than, meaningful'.

ii. The public, who are not experts on NHS organization and management or on clinical matters have been expected to find the flaws in the views expressed by experts. Those experts having been chosen because they support the options put forward.

iii. The information given in writing, visually and spoken is all one sided and the counter arguments and the adverse views that have been expressed by health professionals and managers have not been put before the public so that they can make informed decisions.

iv. The process has been further flawed by using the wife of the vice -chairman of the East Lancashire NHS Hospitals Trust in the public video and presenting her as an ordinary member of the public supporting the proposals about Birthing Centres. After this became public knowledge it was supposed to have been mentioned at the public consultation meetings but it was not done at every one, certainly not at either of the two Blackburn meetings or the Darwen evening meetings.

v. The public are quite unreasonably expected to develop alternative models and to put forward alternative options without being given the information and support that they would need in order to create them.

5. Conclusions.

The flaws in this public consultation are so great as to make the whole process meaningless and any conclusions drawn from it unacceptable.

The Patient and Public Involvement Forum for the East Lancashire NHS Hospitals Trust is of the opinion: 1. That the public consultation exercise should be halted.

2. That the Care Stream Groups should be reconvened with an enlarged membership, particularly to include members of the public, and that 3. These Groups should be charged with the discussion and recommendation of options that spell out in detail the service models, costing in terms of staffing and resources and the effect on patients and relatives and other agencies.

Despite everything that is said above the Forum still firmly believes that the Clinical Services Review presents an unprecedented opportunity to create a patient centred local NHS and deeply regrets that this opportunity is at risk of being wasted.

22ND June 2006